SSINS No.: 6835
IN 84-50
UNITED STATES
NUCLEAR REGULATORY COMMISSION
OFFICE OF INSPECTION AND ENFORCEMENT
WASHINGTON, D.C. 20555
JUNE 21, 1984
Information Notice No. 84-50: CLARIFICATION OF SCOPE OF QUALITY
ASSURANCE PROGRAMS FOR TRANSPORT PACKAGES
PURSUANT TO 10 CFR 50, APPENDIX B
Addressees:
All nuclear power reactor facilities holding an operating license (OL) or
construction permit (CP).
Purpose:
To help eliminate any confusion as to the applicability of the quality
assurance provisions of Appendix B, 10 CFR 50 to certain transport packages
for which a quality assurance program is required by the provisions of 10
CFR 71. It is expected that addressees will review the information provided
in this notice for applicability to their program. Suggestions contained in
this information notice do not constitute NRC requirements and therefore, no
specific action or written response is required.
Background:
Pursuant to 10 CFR 71.12(b), 71.14(b), and 71.16(c)(2), licensees who
transport or deliver to a carrier for transport certain transport packages
are required to have an NRC-approved quality assurance (QA) program. Such a
program must have been approved as satisfying the applicable provisions of
10 CFR 71 Subpart H (formerly Appendix E). An applicant's request for such a
program approval must be in accordance with 10 CFR 71.101(c). Also, pursuant
to 10 CFR 71.101(b) [formerly 10 CFR 71.51], each licensee must establish,
maintain, and execute a quality assurance program that satisfies each of the
applicable criteria of Subpart H. Under the provisions of 10 CFR 71.101(f),
however, a licensee may utilize a QA program which has already been approved
pursuant to 10 CFR 50, Appendix B, provided that the QA program is
established, maintained and executed with regard to transport packages.
Therefore, an Appendix B program is acceptable in lieu of one approved
specifically under Subpart H.
Discussion:
Past inspections of transportation activities and the associated QA programs
of nuclear utilities have sometimes revealed a generic inadequacy regarding
implementation by licensees of Commission-approved, 10 CFR 50, Appendix B,
QA programs for transport packages. Specifically, this inadequacy usually is
evidenced by nonexistent or deficiently written QA audits for transport
packages. Apparently some licensees have erroneously concluded that the
previous
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IN 84-50
June 21, 1984
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NRC approval of the 10 CFR 50, Appendix B, program implies fulfillment of
the implementing QA requirements for transport packages, without
reservation.
Several of the criteria of 10 CFR 50, Appendix B, or 10 CFR 71, Subpart H,
are programmatic (e,g., control of measuring and test equipment, document
control). For these criteria, the associated implementing procedures may
sometimes be common for both transport packaging and nontransport
activities. Certain other aspects, however, are distinctly packaging related
(e.g., procedures controlling procurement of packaging; preparation of
packaging for use, loading, and unloading the packagings; maintenance of the
packaging, QA records, audits, checklists). Consequently, the utility QA
program must include and address all of the applicable elements for
transport packages to meet the intent of 10 CFR 71.101(f). Licensees should
not automatically assume that such implementing procedures developed for
Appendix B are adequate for transport packages unless such procedures do, in
fact, address transport packages.
Recipients of this notice should review the information discussed for
possible applicability to their quality assurance program for transport
packages. No written response to this information notice is required. If you
desire additional information regarding this matter, contact the Regional
Administrator of the appropriate NRC regional office or this office.
Edward L. Jordan Director
Division of Emergency Preparedness
and Engineering Response
Office of Inspection and Enforcement
Technical Contact: A. W. Grella, IE
(301) 492-7746
Attachment:
List of Recently Issued IE Information Notices